1. Who We Are

Anita Lucas Consulting Ltd ("we", "us", or "our") is a UK-based Limited Company providing coaching, training, facilitation, and consultancy services. We are registered in England and Wales, Company Number: 15947095.

For the purposes of data protection law, Anita Lucas Consulting Ltd is the Data Controller of the personal information we collect and process in connection with our services. This means we are responsible for deciding how and why we use your data and for ensuring it is handled lawfully.

We comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. These regulations govern the collection, processing, and storage of your personal data. We process your personal data lawfully, transparently, and fairly. You have the right to access, rectify, and request the erasure of your personal data, and we will ensure your data is stored securely and only for as long as necessary. For more information on your rights under the UK GDPR, please refer to the Information Commissioner's Office (ICO).

2. What This Policy Covers

This Privacy Policy explains how we collect, use, store, share, and protect your personal data when you engage with us, either directly or indirectly (e.g., when we are contracted as an Associate by a larger organisation).

3. What Data We Collect and Why

Type of Data - Purpose - Lawful Basis

• Name, email address, job title, and organisation - To deliver coaching, training, or consultancy - Legitimate interest or contract
• Coaching-related notes (if kept) - To support coaching delivery, where agreed with the client - Consent
• Psychometric assessment results - To prepare for and deliver developmental feedback - Legitimate interest or contract
• Name and email address (coaching log) - For ICF credentialing records - Consent
• Email address (for newsletters) - To send optional communications - Consent
• Communication records - To manage our relationship and maintain records - Legitimate interest

4. How We Collect Your Data

• Directly from you when you contact us, complete forms, or engage in coaching or training.
• Indirectly via a third-party organisation when we are engaged as an Associate (e.g., your employer, or an organisation contracted by your employer, for whom we act as an Associate).
• From psychometric assessment providers where you or your employer have arranged assessments.

5. Sharing Your Data

• With assessment providers (e.g., Hogan) to facilitate feedback (if applicable).
• With the International Coaching Federation (ICF), only if requested during an audit and only with prior consent.
• With third-party data processors (e.g., cloud storage or CRM systems), solely to support business operations, under strict confidentiality agreements.

6. Data Retention

• Coaching records and session notes (if notes are taken with your consent): agreed with you and deleted when coaching programme is complete
• Psychometric reports: deleted promptly after the intervention is complete
• Coaching log (for ICF): retained securely for credentialing audits, only with your permission
• Email addresses for newsletters: until you withdraw your consent (you can unsubscribe at any time)

7. Your Data Rights

• To access the personal data we hold about you
• To request correction of inaccurate or incomplete data
• To request deletion (the “right to be forgotten”)
• To object to or restrict processing
• To withdraw consent where processing is based on consent
• To lodge a complaint with the Information Commissioner’s Office (ICO)
  • Work directly with individual clients or organisations who contract us directly

8. Security of Your Data

We take appropriate technical and organisational measures to secure your personal data, including password-protected systems, encrypted storage, and limited access protocols.

9. Acting as a Data Controller or Data Processor

In most cases, Anita Lucas Consulting Ltd acts as a Data Controller. This includes when we:

• Collect and process personal data (e.g., names, email addresses, session notes, coaching logs) for our own professional records, service delivery, or ICF credentialing

However, we may act as a Data Processor when:

• We are engaged by a third-party organisation (e.g., as an Associate Coach or Trainer) to deliver services to their employees or clients
• The contracting organisation provides us with personal data (e.g., names, email addresses, psychometric reports) and determines the purpose and means of processing

In such cases, we process data strictly under the instructions of the contracting organisation and in line with their privacy policies.

Where we retain any data independently (e.g. for credentialing or compliance), we act as an independent Data Controller and will obtain your explicit consent where required.

10. External links

Our website or materials may contain links to third-party websites or resources. Please note that we are not responsible for the privacy practices, content, or security of these external sites. If you choose to follow a link to another website, we encourage you to review that site’s privacy policy independently.

11: Children’s Data

Our services are not intended for individuals under the age of 16, and we do not knowingly collect or process personal data from children. If we become aware that we have inadvertently received personal information from a child under 16, we will delete it as soon as possible. If you believe we may have collected such data, please contact us immediately.

12. Cookies

Our website may use cookies and similar technologies to enhance your experience, analyse site traffic, and support certain site functionalities. Cookies are small text files stored on your device when you visit a website.

You can control or disable cookies through your browser settings. Please note that disabling cookies may affect how the website functions.

If we implement more advanced tracking or analytics tools in the future (e.g., Google Analytics), we will update this policy and provide appropriate notices and consent mechanisms as required by UK law.

13. Contact Us

If you have any questions or concerns about this policy or your data, please contact:

Anita Lucas Director, Anita Lucas Consulting Ltd

Email: anita@anitalucasconsulting.co.uk

Company Number: 15947095

Registered Address: 62, Marlin Square, Abbots Langley, Herts. WD5 0EG -